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would not suffer economic hardship if the Service did not grant
relief from the income tax liability; (5) petitioner had actual
knowledge that in 1995, Mr. Glaze worked for and received income
from Mayflower; and (6) petitioner had actual knowledge of the
$24 of interest income received jointly by petitioner and Mr.
Glaze from the United States Treasury. Respondent asserts that
these factors weigh against granting relief to petitioner. We
now address each of the factors of Rev. Proc. 2000-15, sec. 4.03,
separately.
1. Marital Status
During 1995, petitioner and Mr. Glaze were married and
resided in the same household; however, Mr. Glaze was frequently
away from home driving a truck for Melton Truck Lines and
Mayflower. Petitioner and Mr. Glaze were divorced on May 26,
1999. This factor weighs in favor of granting relief to
petitioner.
2. Economic Hardship
Respondent contends that petitioner offered no evidence that
she would suffer economic hardship if relief were denied.
Pursuant to section 301.6343-1(b)(4)(ii), Proced. & Admin. Regs.,
economic hardship exists if a levy will cause a taxpayer to be
unable to pay his/her reasonable basic living expenses.
Respondent maintains that respondent’s collection activity would
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